based upon the cooperation that has been received from dentists to date, it is believed this may be achieved within 2 or 3 years.

Representative HOSMER. Did this survey cover only those two points?

Dr. YALE. No, sir; it covered many points. Questions were asked as to the age of the machine, type of machine, and type of film used. Representative HOSMER. Were the machines checked out for leakages and other corrections?

Dr. YALE. Oh, yes.

Representative HOSMER. What did you find out in that respect? Dr. YALE. The data are not as yet computed.

Representative HOSMER. How about for the 1957-58 survey? Dr. YALE. The amount of leakage on the 1957-58 survey? I do not have that data at hand at the moment.

Representative HOSMER. I think those figures would be as important to us as the other figures in bearing on whether the equipment is safe. Dr. YALE. Yes. I can make one interesting note, that we found in the Chicago survey, if my memory serves me correctly, that as the average machine aged, the output decreased. In other words, as the machine became older, the tube, in a sense, became less efficient and produced less radiation. That may supply some information along the line that you suggest.

But as to the actual leakages data, I have that and can submit that if required.

Representative HOSMER. Thank you.

Representative HOLIFIELD. Thank you, sir.

Dr. YALE. Thank you.

(The information requested above by Mr. Hosmer is as follows:)

In the preliminary evaluation of data on leakage radiation in dental X-ray machines by the University of Illinois group, the findings were consistent with the recommendations of the National Bureau of Standards.1 These recommendations state that leakage radiation in diagnostic machines shall not exceed the 0.1 roentgen per hour measured at a distance of 1 meter.

Representative HOLIFIELD. The next witness will be Mr. Sandbank of the American Municipal Association.

STATEMENT OF HAROLD SANDBANK,2 CONSULTANT, AMERICAN

MUNICIPAL ASSOCIATION

Mr. SANDBANK. I am glad to be back here again, Mr. Holifield. This statement is concerned with the role of municipalities in the field of radiation standards. It discusses the responsibilities of local agencies and officials representing local people who live and work with radiation, and who are, therefore, directly concerned with radiation

standards and their applications. It points out what help local authorities can give in this field, and what help they need.

In accordance with the request of the committee, the statement includes comments on major subjects listed for consideration in these hearings. It also includes specific recommendations. The observations in this statement are based upon studies and investigations of the local effects of peaceful applications of atomic energy, including the recent special study made by the American Municipal Association for the Atomic Energy Commission. Some of your committee members are aware of this study.

LOCAL EFFECTS OF ATOMIC ENERGY

In previous testimony before this committee, we have discussed certain details concerning the community effects of peaceful uses of atomic energy. The following are pertinent to the present hearingsI would like to point out that the atomic energy applications, of course, account for only a part of the radiation impact and use in the community:

More than 6,000 atomic energy licensees are operating in 1,500 cities and towns across the country. In addition, there are the nuclear reactors and the many unlicensed installations operated by or for the Federal Government. Enough has already happened in many cities to show that atomic energy development brings with it new considerations in the operation of local government. It means new kinds of local benefits. It also means new kinds of questions and problems connected with the responsibilities of local officials. These include mayors and city council members, as well as the personnel of various departments: health, fire, police, water, zoning, building, and others. In view of the specific local effects and problems, it was good to note the statements by members of the Joint Committee at the time the Federal-State cooperation amendment of the Atomic Energy Act was passed. For example, Senator Anderson, Mr. Price, and other members on behalf of the committee said that local and municipal officials are also to be encouraged to participate in inspection and to work closely with AEC officials. They also said that local and municipal government employees are to receive the benefits of this AEC assistance (training, etc.) as well as State employees.

These statements are in accord with the policy resolutions adopted by municipal representatives at the last municipal congress. I would like to submit a copy of these resolutions.

Representative HOLIFIELD. It will be accepted.

(The resolutions referred to are given in attachments 1 and 2 at the end of this statement, pp. 521 and 522.)

Mr. SANDBANK. We regret, however, that it is not possible to report any significant progress in providing Federal encouragement and assistance to localities. They are still being bypassed. Far from being encouraged, they are not even being consulted. This situation is unwise and can be hazardous. Local communities have a key role. in providing an atmosphere that is receptive to sound progress in this field, and in helping to provide adequate safeguards for public protection against the hazards. The attitudes and actions of local people can directly help or hinder peaceful nuclear development. In our

previous testimony, incidentally, Mr. Holifield, we pointed out some specific examples of this in various cities throughout the country. This is demonstrated also in the field of radiation standards.

NATURE OF MUNICIPAL INTEREST IN RADIATION STANDARDS

Cities have a direct interest in standards for a number of reasons. They are consumers of standards, utilizing them in connection with local ordinances and regulations. They enforce compliance with standards through surveys and inspections for radiation safety. Sometimes, in effect, they may develop standards by modifying or disregarding existing recognized standards and establishing new requirements of their own in local regulations.

Cities are also concerned with radiation standards because of the economic and social factors involved. These standards can affect zoning and land use practices and can influence the economy and development plans of communities.

Many cities have already enacted ordinances dealing with radiation: Philadelphia, Cincinnati, Houston, New York City, Cleveland, San Francisco, Los Angeles, and many others. Specific examples will serve to illustrate the range of activity in this area. Last year, Orlando, Fla., enacted a comprehensive ordinance on radiation. In various sections it specified as requirements the recommendations of the National Committee on Radiation Protection, at the same time providing for local inspection and control. The ordinance contained some special requirements: for example, no food products or drugs treated by radiation are to be sold or distributed in the city without express prior approval of the commissioner of health.

Also last year, the village of Muttontown, Long Island, N.Y., adopted a new village ordinance. It permits certain radiation applications in the community if the village board determines that the proposed uses are safe. The board may require expert testimony and the installation of monitoring devices at the applicant's expense. However, no reference is made to any nationally recognized criteria. As additional cities enact ordinance for use of radiation, the situation could become chaotic if local authorities are not promptly provided with adequate guidance and assistance. Municipal representatives recognize this and in their policy statements have urged adoption of uniform national standards. On the basis of the existing situation, the following recommendations in this area are made. 1. Push ahead with development of uniform standards and criteria on a national basis so that they will be available for reference and use in connection with local ordinances.

2. Prepare recommended model ordinances suitable for adoption by local authorities. In this way, standards can be incorporated in regulations in a uniform manner.

3. Set up a positive program for supplying local officials with information and guidance on radiation standards. Tell them that the information and assistance are available and encourage them to use the service.

4. Enlarge the capacities of the Federal Radiation Council. Provide representation from groups and interests outside the Federal Government.

On this last point: Congress has wisely established the Federal Radiation Council as a statutory body with vital functions and has made it possible to expand the organization structure of the agency.

Local representatives view the "establishment of the Federal Radiation Council as a salutory move toward the much needed coordination of Federal agencies involved" in the radiation field. From the local viewpoint, it would certainly be desirable if the Council would act up to the full potentialities of its charter. It can and should reflect more than the concern and views of Federal agencies and experts. In its deliberations the Council should have the benefits of representation from all levels of government--including the local government, and from labor, industry, and other nongovernmental groups. The Council could provide importance guidance for the national policy decisions that must be the basis for sound radiation standards and for their practical application locally. It can help to stimulate needed research and development work on standards. And the Council should see to it that adequate consideration is given to the economic and social factors related to the application of standards. Finally, the Council can, if it will, have an important role in overcoming confusion and building public understanding about the benefits and problems of atomic energy and radiation. To help do these things, the following should be done:

(a) An Advisory Board to the Council should be established. It could provide the means for increased representation from non-Federal groups, without increasing the size of the Council. The Board could be as large as necessary without making the Council itself unwieldy. Membership could include State and local government, labor, industry, and professional groups. The Board could meet separately, and would be independent in its policy views and findings. Joint meetings of Board and Council could be held as necessary.

(b) The Council should have adequate staff so that it can carry out its responsibilities under its charter. There should be sufficient staff to provide any necessary assistance to the Advisory Board.

We mention the professional groups here for a particular reason: that is, that at this stage the professional groups are not always being brought into the questions that relate to radiation standards and applications of atomic energy. For example, in connection with recent considerations on sites for nuclear reactors, there were no members from the planning profession, there were no representatives from the architectural field, there were no municipal representatives. How is it possible to develop recommendations on site locations in connection with matters which have specific local interest, without bringing in some of the people who know about local problems in the field of development?

PRACTICAL PROBLEM AREAS

Inspection and training

The effectiveness of standards depends upon compliance and methods of enforcement. Consequently, inspections to assure compliance are of local concern. At present there is a serious shortage of qualified persons in this field. This has been previously mentioned to your committee by the Advisory Committee on Radiation, and Dr. Wil

liams has mentioned this problem to you in earlier testimony during these current hearings.

It is imperative for reasons of safety that personnel at all levels of government be trained in radiation protection work. The local level should not be neglected. The participation of trained local personnel could result in more frequent inspections and increased assurance of safety, and it also might make for more economical inspections.

In the case of many radiation uses, local personnel, with proper training, could make the necessary inspections. Many among local personnel have the necessary professional background to undertake this work: for example, those in health, engineering, and inspection departments. However, special training in radiation is essential.

Public Law 86-373 makes provision for Federal assistance in training local personnel, but so far there has not been much progress. A definite program should be developed, and local personnel should be encouraged to participate. Municipal representatives have urged this be done, and the Joint Committee has recommended it. On this point, a neutral or passive attitude on the part of Federal agencies is not going to do the job. We need a practical program, and we need specific encouragement for the local people to participate.

Information and notification

Adequate and prompt information is essential if local authorities are to properly discharge their responsibilities for local safety and welfare. Municipalities should be promptly notified when atomic energy licenses are issued affecting their jurisdictions. At present, although the locality is the first to get the impact, it is often the last to know. Delay in this area can be dangerous. This has been illustrated in the case of several cities. Is there any sound reason why the AEC should not directly notify cities when it issues license? Is it necessary for cities to be notified only through the States on a delayed basis? Some industry officials feel the community should be notified before the license is issued.

In this connection, the proposed criteria for Federal-State cooperation contain no provision for local notification or for local participation in training and inspection. Specific provisions for this purpose should be made a requisite to any Federal-State agreement. This is very important. The association has made specific resolutions on this point, and we hope that the committee will do what it can to see that proper notification and proper information will be supplied to communities.

Representative HOLIFIELD. The requirement by the AEC that the application file notice with his local political subdivision would be all that would be necessary in this case, and this would take a burden of paperwork off the AEC. If the State health departments refuse to do their duty, let us put it on the applicant.

Mr. SANDBANK. Mr. Holifield, it is not such a matter of the State refusing.

Representative HOLIFIELD. Or you could handle this by municipal ordinance, requiring any user of isotopes or atomic energy material to file with the local body a notice of intention. This is just as simple as taking out a building permit or any other kind of a local license.